SECTION 117 OF THE HIGHER EDUCATION ACT OF 1965
Section 117 of the Higher Education Act requires institutions to disclose to the Department of Education (ED) contracts, grants, agreements with or gifts from a foreign source, with a value of $250,000 or more, considered alone or in combination with all other gifts from or contracts with the same foreign source, within a calendar year. Once the $250,000 threshold is met, all disaggregated individual gifts/contracts that add up to the threshold (and beyond) must be reported. Transactions which could trigger the $250,000 threshold occur in many different units across the University of Illinois System. As such, units should upload all foreign source contracts and gifts received in any amount, no matter how small, to the University of Illinois Foreign Gift and Contract Data Repository.
Disclosure Reports are submitted to the Department of Education by designees of each University within the University of Illinois System biannually: January 31 (covering the previous July 1-December 31 period) and July 31 (covering the previous January 1-June 30 period). In order for those designees to submit their reports by the two statutory reporting deadlines, units need to submit their data in a timely manner prior to the conclusion of the reporting periods.
Penalties for knowingly or willfully failing to comply with this reporting requirement include loss of Title IV federal student aid funds and reimbursement to the U.S. Treasury for the full cost of obtaining compliance. As of July 2025, 22 institutions have been investigated for failing to report or under-reporting.
How and When to Submit Gifts and Contracts to the Repository
What must be reported?
Every gift and contract with a foreign entity or individual, regardless of dollar value.
What are the reporting deadlines?
Activity Reporting Period: January 1 - June 30; Submission Deadline: July 14th (or the Friday prior if it falls on a weekend)
Activity Reporting Period: July 1 - December 31; Submission Deadline: December 14th (or the Friday prior if it falls on a weekend)
Where can I get training/additional information on submitting data to the repository?
If you have been assigned responsibility to assist with reporting foreign gifts and contracts for your unit, please contact the University Compliance Office staff at complianceoffice@uillinois.edu to request additional training.
REPOSITORY
RESOURCES
Frequently Asked Questions
DOE Section 117 Webinar
U.S. DEPARTMENT OF EDUCATION
Section 117 Website
Statute: 20 U.S.C. 1011F
CONTACT
complianceoffice@uillinois.edu